Whose Job is Exclusion Screening?

Posted by Frank Strafford on June 5, 2015 in Exclusion Screening,

Whose Job is Exclusion Screening?

Is it the Compliance Department’s or HR? Many healthcare companies find this particular issue a source of confusion, which often results in astronomical penalties. Exclusion screening requires a specific policy and procedure that must be strictly implemented at all times. Both HR and the Compliance Department play important parts in achieving precisely this.

 

The role of Human Resources begins right at the recruitment stage, and in the case of exclusion, culminates in the termination phase. During the initial interview, the HR head must ask proper questions in order to determine if the potential employee fills the job requirements. Individualized Assessment should be used in case of a past criminal misconduct showing up in the screening process, as a best practice endorsed by the Equal Employment Opportunity Commission. HR must also do thorough background checks for all employees, as well as monthly monitoring post-hire.

 

The Compliance Department in turn must make sure that the company’s compliance program is strong, effective, and strictly implemented. In developing their compliance policies, the department should ensure there are both general standards and case-by-case procedures for their employees. Compliance Department is also responsible for the training/education, monitoring and auditing, enforcement, investigation, and reporting of any compliance issues.

 

It is also the job of the people making up the company’s Human Resources and Compliance Departments to be familiar with OIG protocol and any guidance involving exclusion screening. Being updated on these guidelines will ensure a thorough investigation in the case of exclusion.

 

Both HR and the Compliance Department play proactive roles in exclusion screening and policy implementation. Along with an effective compliance program, these departments must work together to ensure that mandatory exclusions are enforced, and penalties avoided altogether.

 

 

About Frank Strafford

About Frank Strafford

Related Articles

HCFAC Turns 25 & Continues to Thrive in ...

August 23, 2022

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) established a national Health Care Fraud and Abuse Control Program (HCFAC or Program) under the joint direction of the Attorney ...

Conducting Investigations and Responding to Government ...

April 28, 2021

Streamline Verify is proud to have had the privilege of working with the Journal of Regulatory Compliance at Loyola University Chicago School of Law to help galvanize research and resources for the pu...

The end of the Public Health ...

April 27, 2022

Recently, multiple organizations have urged President Biden and the Department of Health and Human Services (HHS) to again extend the Public Health Emergency (PHE) designation and the emergency declar...

Understanding OIG Exclusions

OIG Exclusions Screening Process

Exclusion FAQS

Quick OIG Exclusion Basics

Employing Excluded Individuals

Consequences to Employing an Excluded Individual

OIG Compliance Law

Laws and Publications on OIG Compliance

More Compliance Resources

The Verify Way!

We build the best, so you can perform at your best.

Trusted for Good Reason

  • ✓ Guaranteed accurate
  • ✓ Certified Secure
  • ✓ Audit Proof
  • ✓ Feature-rich reporting
  • ✓ Round the clock real-time-data
  • ✓ Processing fully automated

Security First

  • ✓ Cloud hosted
  • ✓ Encrypted data
  • ✓ Real-time backups

Trusted for Accuracy

  • ✓ Physical security
  • ✓ Restricted access
  • ✓ Single sign-on
  • ✓ Password security
  • ✓ Certified secure
  • ✓ Cross checking

HEALTHCARE ESTABLISHMENTS NATIONWIDE COUNT ON STREAMLINE VERIFY

5

60%

Average workload reduction by implementing the Streamline Verify program

5

10K

Establishments trust Streamline Verify nationwide

5

2011

Serving the healthcare industry’s unique compliance needs since 2011

5

24X

Setting standards with hourly synchronization to primary source data

[class^="wpforms-"]
[class^="wpforms-"]